Low pitched roof perimeter rule and built-up roofing

NOTICE: This is an OSHA Archive Document, and may no longer represent OSHA Policy. It is presented here as historical content, for research and review purposes only.

June 24, 1981

MEMORANDUM FOR: CURTIS A. FOSTER
REGIONAL ADMINISTRATOR

THRU: JOHN B. MILES
FIELD COORDINATOR

FROM: BRUCE HILLENBRAND
DEPUTY DIRECTOR, FEDERAL COMPLIANCE AND STATE PROGRAMS

SUBJECT: 29 CFR 1926.500(g)(1): Guarding Low-Pitched-Roof Perimeters

REFERENCE: Your memorandum, dated May 18, 1981, same subject.

It is the intent of 29 CFR 1926.500, roofing standard effective on January 13, 1981, to regulate only the guarding of low-pitched-roof perimeters during the performance of built-up roofing work. 29 CFR 1926.104, 1926.105, 29 CFR 1924.451(u)(3) and 29 CFR 1926.28 are to be enforced for other types of roofing work, such as to be found between points A and B on your sketches.

The eave is at point B as indicated on your two sketches and 29 CFR 1926.500(g) does not apply to anyone installing the built-up roof in the situations depicted in your sketched since the eaves are less than 16 feet above the ground. Additionally, no citation could issue for violation of other fall protection standards (e.g. 1926.28(a)) with regard to employees performing built-up roofing work in your sketches because of the preemptive effect of 1926.500(g). The Directorate of Safety Standards Programs plans to revise the standard with a modification of the roofing paragraphs to address fall distance instead of eave distance as soon as time and priorities permit.